From Devon Sayers and Victor Blackwell CNN |
12/11/2013, 2:55 p.m.

A rally is held at the Georgia State Capitol for Kendrick Johnson on Wednesday, December 11, 2013. Photo by Devon Sayers/CNN.

Harrington has previously told the family that the organs were missing when he took custody of the body after the GBI autopsy, and Copeland said last month that the funeral home "absolutely, positively" did not receive the organs.

"There is no collusion between Mr. Harrington and any law enforcement. In fact, I'm appalled that anyone would even suggest that," Copeland told CNN.

William Anderson, a pathologist hired by the Johnson family's attorney, further told the family "that our son was stuffed with newspaper. At no time did we ever authorize the removal of our son's inner organs for any purpose whatsoever," the complaint says.

Harrington Funeral Home never informed the family the organs were missing, and the GBI said it replaced all of the organs after the autopsy, the complaint alleges.

Harrington initially said "one or two organs might be missing," according to the complaint, but in an October 4 letter to the family's attorney, C.B. King Jr., Harrington said the organs had been "destroyed" and "discarded ... before the body was sent back to Valdosta," where the funeral home took custody of the body.

"It is our belief that Mr. Harrington, at best, misled us as to the condition of our son's body, and at worse, is responsible for the removal and destruction of his organs, and, thus, desecration of our son's body," the complaint says.

The family concludes by requesting an investigation and alleging that Harrington engaged in fraud by misleading the family into believing Johnson's remains were intact and "facilitated a coverup" that deprived pathologists of "the means by which to determine how he may have died," the complaint says.

The funeral home has not commented to CNN in the past, but Harrington said in the October letter to the Johnsons' attorney that the prosector -- an agent who prepares bodies for pathological examination -- discarded the organs.

The secretary of state's office confirmed receiving the Johnsons' complaint Tuesday, but would not comment.

The Georgia Board of Funeral Service says all investigations are confidential, but after a formal hearing, several resolutions are possible: It can close the probe and take no action; it can issue a "letter of concern," which won't be made public; it can issue a public inspection report; or it can publicly or privately handle any violation with the funeral home.